Privacy Policy

Last updated: August 14, 2026

This Privacy Policy describes how GT Foods LLC (the “Company”, “we”, “us”, or “our”) collects, uses, and discloses your personal data when you visit, use our services, or make a purchase from lazysnark.ge and lazysnarkadventure.com (collectively, the “Sites”), including in-person purchases at markets, festivals, and other events, or otherwise communicate with us (collectively, the “Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services, whether you are a customer, website visitor, or another individual whose data we have collected pursuant to this Privacy Policy.

Please read this Privacy Policy carefully. By using and accessing any of the Services, you agree to the collection, use, and disclosure of your data as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access any of the Services.

This Privacy Policy is available in Georgian (ქართული), English, and Russian (Русский). Georgian is the original and legally binding language of this Privacy Policy, in line with the Law of Georgia on Personal Data Protection, which requires information to be provided to data subjects in the national language of Georgia. In case of any discrepancy between language versions, the Georgian version shall prevail.

This Privacy Policy is governed by the Law of Georgia on Personal Data Protection (as amended). Where Georgian law does not provide specific guidance, we look to the principles of the EU General Data Protection Regulation (GDPR) as a subsidiary reference.

1. Our Approach to Your Data

We follow the principle of data minimization: we collect only the personal data that is reasonably necessary to provide our products and Services, and we do not ask for information beyond what a given purpose requires. Where a feature is optional, providing the related data is optional too.

2. Changes to This Privacy Policy

We may update this Privacy Policy from time to time, including to reflect changes to our practices or for other operational, legal, or regulatory reasons. We will post the revised Privacy Policy on the Sites and update the “Last updated” date.

3. What Personal Data We Collect

The categories of personal data we obtain about you depend on how you interact with our Sites and use our Services.

Data you provide directly, such as:

Basic contact details — name, address, phone number, email address.
Order information — name, billing address, shipping address, payment confirmation, email address, phone number.
Account information — username and password.
Shopping information — items you view, add to your cart, or add to your wishlist.
Customer support information — anything you choose to share with us, for example in a message to us.

Some features of the Services require you to provide certain data directly. You may choose not to provide it, but this may prevent you from using or accessing the relevant feature.

We do not collect or process special categories of data about you (e.g., data concerning health, religious or political beliefs, or biometric data) unless you voluntarily share it with us (for example, an allergy note in an order comment). If you do so, we process it only for the purpose you shared it, with the additional safeguards Georgian law requires for this kind of data.

Data we collect through Cookies — see Section 6 below.

Data we obtain from third parties, including:

Vendors and service providers who support our Sites and Services, such as our website platform (WooCommerce) and our hosting provider.
Our payment processors, who collect payment data (e.g., bank account, card information, billing address) to process your payment and fulfill your order.

Any data we obtain from third parties is treated in accordance with this Privacy Policy. We are not responsible for the accuracy of data provided to us by third parties, nor for their own privacy practices — see Section 10 below.

4. How We Use Your Personal Data

We only process your personal data where we have a valid basis for doing so under Georgian law — typically because it’s necessary to fulfill our contract with you, because you’ve given consent, because we have a legitimate business interest that doesn’t override your rights, or because we’re required to by law. In particular:

Providing products and Services — processing payments, fulfilling orders, sending order- and account-related notifications, managing your account, arranging shipping, handling returns and exchanges. Basis: fulfilling our contract with you.
Marketing and advertising — sending marketing, advertising, or promotional communications. Basis: your consent. We only send marketing communications where you’ve consented, and you can withdraw that consent at any time — see Section 12.
Security and fraud prevention — detecting, investigating, and acting on suspected fraudulent, illegal, or malicious activity. Basis: our legitimate interest in keeping the Services and your account secure, and, where applicable, a legal obligation.
Customer support and improving our Services — responding to you and maintaining our relationship with you. Basis: our legitimate interest in being responsive and providing effective service.
Accounting and tax compliance — issuing invoices and meeting bookkeeping and tax obligations. Basis: legal obligation.

5. Managing Your Marketing Preferences

If you’ve subscribed to our newsletter or other marketing communications, you can unsubscribe at any time, free of charge and without giving a reason:

by using the unsubscribe link included in every marketing email, or
manually, in your account settings under My Account.

Once you unsubscribe, we stop sending marketing communications, though we may still send you non-promotional messages related to your account or orders.

6. Cookies

Like most websites, we use Cookies on our Sites to operate and improve them (including remembering your preferences) and to understand how the Services are used. We may permit service providers to use Cookies on our Sites for these same purposes.

Most browsers accept Cookies by default; you can set your browser to remove or reject them. Blocking Cookies may affect how parts of the Services work.

7. How We Disclose Personal Data

We may disclose your personal data to:

Service providers who perform services on our behalf (e.g., hosting, payment processing, fulfillment and shipping, customer support), under a written agreement that requires them to process data only on our instructions and to keep it secure.
Our authorized partner retailers, through whom our products are sold. Purchases made through a partner retailer are governed by that retailer’s own privacy policy.
Third parties you direct us to, or where you otherwise consent to disclosure (for example, to ship you products).
Authorities or courts, where required to comply with a legal obligation, or to establish, exercise, or defend a legal claim.
A successor entity, in connection with a merger, acquisition, or similar business transaction.

We do not sell your personal data.

8. International Data Transfers

Our key service providers — payment processing and shipping/delivery — are based in Georgia. Our website hosting is provided through a Georgia-based reseller, whose infrastructure is physically located in Germany. Germany is included on the list of countries recognized by the State Audit Service of Georgia as providing an adequate level of data protection, so this hosting arrangement does not require any additional safeguards under Georgian law.

We also use Cloudflare, Inc. (United States) to provide Cloudflare Turnstile, a bot-detection tool that protects our contact form from spam and abuse. Turnstile processes limited technical data (such as your IP address and device/browser signals) on our behalf. Where we or any other service provider process your personal data outside Georgia, we only do so on a legal basis recognized by Georgian law: an adequate level of data protection in the recipient country, appropriate contractual safeguards with the recipient, or, where applicable, your consent after being informed of the transfer.

9. User-Generated Content

The Services may let you post product reviews and other content. If you submit content to a public area of the Services, that content will be public and accessible to anyone. You can delete content you’ve posted at any time — via My Account where available, or by contacting us at the Contact details below. We are not responsible for how others use content you make public.

10. Third-Party Websites and Links

Our Sites may link to websites or platforms operated by third parties. We do not control and are not responsible for the privacy or security practices or content of such third-party sites.

11. Children’s Data

The Services are not intended for children under the age of 16, and we do not knowingly collect personal data from children under 16. Under Georgian law, a minor aged 16 or older may consent to the processing of their own data; for a minor under 16, we require the consent of a parent or legal guardian. If you are a parent or guardian and believe your child has provided us with personal data, please contact us at the Contact details below to request its deletion.

12. Your Rights

You have the following rights in relation to your personal data under Georgian law. These are generally free of charge, subject to the exceptions set out in the law.

Right to information. Ask whether we process data about you and request details on the processing. We respond within 10 working days (extendable by up to 10 further working days in justified cases).
Right to access and obtain a copy. Request a copy of the personal data we hold about you. Within 10 working days. We provide it in the form in which we hold it, or, on request, in another commonly used electronic format (e.g. PDF or CSV) where feasible.
Right to rectification. Ask us to correct, update, or complete inaccurate or incomplete data. Within 10 working days.
Right to erasure. Ask us to stop processing, erase, or destroy your data. Within 10 working days.
Right to blocking. Ask us to temporarily pause processing of your data in specific circumstances set out by law — for example, while you dispute the accuracy of the data, or while your erasure request is being considered. Within 3 working days.
Right to data portability. Where processing is automated and based on your consent or on our contract with you, request a copy of your data in a structured, commonly used, machine-readable format, or ask us to transfer it to another controller, where technically feasible.
Right to withdraw consent. Where we rely on your consent (e.g. for marketing), withdraw it at any time, free of charge, without giving a reason — see Section 5 for marketing specifically.
Right to appeal. If we decline your request, we’ll explain why and how to appeal. You can also lodge a complaint directly with the State Audit Service of Georgia, a court, or a superior administrative body, without raising it with us first — see Section 13.

You can exercise these rights by contacting us at the Contact details below. We may need to verify your identity first. We will not discriminate against you for exercising these rights.

13. Complaints

If you have concerns about how we process your personal data, you’re welcome to contact us first at the Contact details below. You also have the right, at any time, to lodge a complaint directly with the State Audit Service of Georgia (www.sao.ge), or to apply to a court, without needing to contact us first.

14. Security and Retention of Your Data

We take appropriate technical and organizational measures to protect your personal data. No method of transmission or storage is completely secure, so we cannot guarantee absolute security.

We retain personal data only for as long as necessary for the purpose it was collected — for example, to maintain your account, provide the Services, meet legal or tax retention obligations, or resolve disputes. Where legally required, we notify the State Audit Service of Georgia of any data security incident within 72 hours of becoming aware of it, and, where an incident poses a significant risk to your rights, we notify affected individuals without undue delay.

Contact

For questions about this Privacy Policy, or to exercise any of the rights described above, please contact us at: gtfoods.georgia@gmail.com.